EPA Releases Criteria for Recognizing Labs for Energy Star Qualification Testing

The EPA released draft criteria for labs picked to test for Energy Star qualifications, as the agency moved to strengthen qualification and verification rules for the program. The requirements include those for in-house labs that the agency is considering allowing for certain product categories. Comments on the Draft Conditions and Criteria for Recognition of Laboratories are due May 28, the agency said.

All labs must maintain accreditation to ISO/IEC 17025 by an EPA-recognized accreditation body, the agency said. They should make available to the EPA “evidence and details” of accreditation and authorize the accreditation body to share assessment information with the agency. Labs are required to notify the EPA or the Department of Energy of “any attempt to hide or exert influence over test results.” They also must agree to participate in “inter-laboratory testing” when asked, it said.

To be recognized, labs also must provide documentation about their “impartiality and freedom of laboratory management and personnel from any undue internal or external commercial, financial or other pressures and influences that may adversely affect the quality of their work.” In the case of manufacturers’ in-house labs, evidence must be provided that laboratory employee compensation or annual bonuses are not tied to financial performance of the parent company, the agency said. In-house labs’ engineering staff should not “originate with or return to the parent company, or otherwise look to the parent company for career advancement,” it said.

In-house lab employees are required to participate in and regularly pass “third-party ethics and compliance audits” and the labs should have in place “mechanisms for reporting and responding to attempts to exert influence on the test results.” The EPA is proposing to supplement ISO/IEC 17025 requirements to ensure independence of in-house labs from the manufacturer, the agency said. “EPA’s goal is to allow for in-house testing with sufficient controls to ensure such testing remains independent."

Meanwhile, several CE and IT device makers urged the EPA to allow testing by “independent” in-house labs. Motorola said that, unlike other Energy Star products, set-top boxes require the installation and use of specialized and proprietary gear that replicates the operation of a typical cable headend. “Costs for acquiring the appropriate equipment along with the needed laboratory infrastructure to test the many types of set-top boxes on the market can easily exceed $1 million,” the company said. Third-party testing facilities would need to “charge very high rates” for testing the boxes and “these testing costs would likely represent a much higher percentage of the product cost than [for] other consumer electronic equipment,” Motorola said, strongly urging the EPA to allow testing of boxes by in-house labs.

DirecTV cited other concerns in seeking testing by in-house labs. Set-top boxes require that service providers authorize services on them before testing, it said, and purchase of a service providers box through retail “typically requires” a subscription with the provider that a third-party lab won’t be willing to buy. “Difficulties such as these will make it very expensive for even one independent third-party lab, let alone a robust market of labs, to offer the capability to test a variety of service providers’ set-top boxes."

IBM sought testing by manufacturers’ in-house labs for enterprise IT equipment. Enterprise IT products can be very expensive, the company said, so the EPA should consider “innovative methodologies for sampling, procuring and testing products to protect the value of the products and to make the cost of the program reasonable.” Also to be considered is the fact that such products are configured and ordered by the user, the company said. “If systems are shipped to a third-party lab, remote tuning will be required for performance measurements,” IBM said. “For qualification testing, hardware is typically very limited and companies want to protect their competitive advantage and not release systems to third parties prior to any planned announcement."

Dell urged continuation of the practice of qualification testing in “approved” manufacturer labs. That would help achieve the goals of making available more energy efficient products and promoting market adoption of more efficient products while “limiting the cost burden to consumers.” Third-party testing would be “prohibitively expensive” for manufacturers, it said. Requiring qualification testing by third-party labs would “create issues with cost and time-to-market that would out outweigh any benefits of such an approach,” said GE: “Absent a compelling reason why certified manufacturer labs should not perform pre-qualification testing, EPA should accept results from such manufacturer labs.”